Allergen control checklist:

manufacturing premises

Checklist for local authority enforcement officers to audit allergen

control measures when carrying out inspections of manufacturing
premises
Name and address of premises:

Name of inspector: Date: Ref:

This checklist is not exhaustive and is intended to be a guide only.
People

Identify the total number of food handlers and check that they have been trained

in food allergen control.

Has in-house training been recorded?

Are staff able to recognise which ingredients are the allergens of concern and why?

Can staff identify potential allergen cross-contamination situations?

Are there clear procedures for hand washing?

Are instructions for clothing requirements (including laundering) clear?

Are staff aware of re-work procedures?

Are staff aware of the waste management procedure?
Is there a protocol for people moving around the site, for example people changing
production line or site, maintenance staff, trips to the canteen and visitors?

Raw materials and supply chain

Is there an appropriate and proportionate policy for assessing the allergen status of
ingredients?

If appropriate, is there a protocol for assessing those ingredients used by suppliers
or co-packers?

Is there a protocol for ensuring that any change in supplier is accompanied by the
appropriate checks?

Is the allergen status of all ingredients checked with suppliers and reviewed regularly?

Do suppliers notify the manufacturer of changes in the allergen status of the
materials they supply?

Are there protocols to ensure the handling of allergenic ingredients does not cause
contamination of other ingredients?

FSA/1286/0908
Storage

Are steps taken to ensure that non-allergenic ingredients do not come into contact
with allergens in subsequent handling and storage? For instance, are allergenic raw
materials stored in clearly identified areas where possible, for example by using
colour-coded boxes or demarcation of storage areas using painted lines on the floor?

Are allergenic raw materials de-bagged or de-boxed, placed in dedicated lidded and
labelled containers, and made easily identifiable?

Sieving

Is it possible to have dedicated sieving equipment?

Is it possible for allergenic ingredients to be sieved after all other raw ingredients
have been sieved for the day?

Is sieving equipment thoroughly cleaned after allergenic ingredients are sieved?

Manufacturing premises, equipment and processes

Is it possible to manufacture non-allergenic lines in a different part of the

production area?

Is it possible to erect physical barriers between the production lines to avoid cross-
contamination?

Is it possible to use dedicated equipment for non-allergenic lines?

Is it possible to minimise unnecessary movement of materials?

Could cross-contamination be reduced by appropriate scheduling of production
runs, including the appropriate cleaning of equipment between production runs?

Are recipes available in all mixing areas so that staff can adhere to mix instructions?

Is it possible to manage re-work better to ensure that residual material containing an
allergen is not re-worked into a product not containing the allergen?

Is it possible to use a separate air supply to avoid contamination?

Is it possible to prevent equipment movement around the site, for example
maintenance tools and food trays?

Are held-over products suitably labelled?
Cleaning

Are there adequate procedures in place for cleaning both production and packaging
machinery, and are records kept?

Is there a protocol to ensure that the cleaning of one production line does not
contaminate another, (as could happen when employing compressed air cleaning)
or an area which has already been cleaned? Are dry mix areas cleaned from the
top down?

Are spillages that occur during production, storage and transportation cleaned up
immediately to ensure that there is no subsequent allergen cross-contamination?

Is there a protocol for spillages of allergenic materials where they are labelled and
physically moved away from the non-contaminated ingredients and work in progress?

Are there dedicated tools (or adequate cleaning procedures where tools are not
dedicated) for non-allergenic ingredients?

Is the cleaning protocol validated as ‘fit for purpose’ and is compliance monitored?

Does the cleaning regime include the laundering of protective clothing?

Packaging

Are there procedures for checking that the correct labels are applied to products
and are these procedures audited regularly?

Are there checks in place between processing and packing to ensure the correct
packaging is used, for example the use of automated label verification systems?

Is there a protocol for destroying old packaging when a recipe change is introduced?

Are there systems in place to ensure that packaging is removed at the end of a run,
including any packaging that may be in the wrapping machine?

Is there a procedure for removing packaging from wrapping machines and labelling it
before returning it to the stores?

Is there a protocol to ensure that the correct outer packaging is used for multi-pack
products and that allergen information appears on, or is visible through, both the
inner and outer wrappers?

Re-work

Is re-work clearly identified so it can be tracked in the manufacturing process? For

example, oils used for cooking allergenic foods (such as nuts, shellfish and fish)
should not be used subsequently for cooking products not containing the allergen.
New product development

During product development, is consideration given to substituting allergenic ingredients?

Reformulating products

Has reformulation of a product been considered with a view to phasing out

allergenic ingredients?

Extending brands into another product line

Is consideration given to the impact of extending a brand name into a different product
sector, for example an established chocolate product giving its name to an ice cream –
especially if an allergen is then introduced that was not present in the original product.

Factory trials and consumer testing

Are measures taken when conducting factory trials to avoid allergen cross-
contamination with existing products, i.e. is information on the presence, or potential
presence, of allergens available to those involved in factory trials or taste testing?

Is there a protocol for providing allergen information during consumer testing?

Allergen-free foods

If allergen-free foods are produced, are there procedures in place to ensure such
claims are justified?

If lists of foods that are free from particular allergens are produced, are these
regularly reviewed and updated?

Allergen risk review

Are allergen management systems monitored and reviewed to provide assurance

that they are working correctly? These should include:
• the review and verification of the hazard analysis and hazard management system
• product and ingredient specifications
• operating procedures
• cleaning procedures
• training records – demonstration of competence
• analysis and investigation of customer complaints, with appropriate actions taken